1 Melissa Newel (#148563) NEWEL LAW 2 2625 Alcatraz Ave., Suite 132 Berkeley, CA 94705 3 (510) 316-3827 4 [email protected]

5 Attorney for Plaintiff RAE D. DENNY 6

7 UNITED STATES DISTRICT COURT 8 EASTERN DISTRICT OF CALIFORNIA 9 10 RAE D. DENNY, No. 1:24-CV-01438 (GSA) 11 Plaintiff, 12 v. STIPULATION FOR BRIEFING 13 EXTENSION; ORDER COMMISSIONER OF 14 SOCIAL SECURITY, 15 Defendant. 16

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21 On November 22, 2024, Plaintiff Rae D. Denny filed the instant civil action for judicial 22 review of the defendant Commissioner of Social Security’s decision denying her application for 23 Social Security disability benefits. (ECF Doc. 1) The Defendant responded to Plaintiff’s 24 Complaint on January 30, 2025. (ECF Doc. 10) Plaintiff’s motion for summary judgment is 25 currently due to be filed on or before March 3, 2025. 26 Pursuant to this Court’s Scheduling Order, Plaintiff seeks an extension of thirty (30) days 27 to file her motion. (ECF Doc. 5 at p. 3:20-21) This is Plaintiff’s first request for an extension of 28 1 time. Plaintiff’s counsel seeks the extension to effectively advocate for Ms. Denny. Plaintiff’s 2 counsel has conflicting briefing deadlines in other matters and, because Plaintiff’s counsel was 3 not involved at the administrative level, a close review of the administrative record concerning 4 Plaintiff’s medical issues and vocational background is necessary and required. See, Costa v. 5 Comm’r. of Soc. Sec. Admin.,

, 1134 at n.1 (9th Cir. 2021) [noting “social security 6 disability cases are often highly fact-intensive and require careful review of the administrative 7 record, including complex medical evidence.”]. The defendant has no objection to the requested 8 extension. 9 Respectfully submitted, 10 Dated: February 24, 2025 NEWEL LAW By: Melissa Newel 11 Melissa Newel 12 Attorney for Plaintiff RAE D. DENNY 13

14 Dated: February 24, 2025 MICHELE BECKWITH 15 Acting United States Attorney MATTHEW W. PILE 16 Associate General Counsel Office of Program Litigation, Office 7 17 18 By: Justin L. Martin* JUSTIN L. MARTIN 19 Special Assistant United States Attorney Attorney for Defendant 20 (*authorized by email on 2/24/25)

21 ORDER 22 As stipulated, Plaintiff is granted a 30-day extension to and including April 2, 2025 to file 23 a motion for summary judgment 24

25 IT IS SO ORDERED. 26 Dated: February 25, 2025 /s/ Gary S. Austin 27 UNITED STATES MAGISTRATE JUDGE

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